Zalma on Insurance
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Insurance Claims professional presents articles and videos on insurance, insurance Claims and insurance law for insurance Claims adjusters, insurance professionals and insurance lawyers who wish to improve their skills and knowledge. Presented by an internationally recognized expert and author.
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September 05, 2025
Interpleader Helps Everyone Potential Claimant to Insurance Proceeds

Interpleader Protects All Claimants Against Life Policy and the Insurer

Who’s on First to Get Life Insurance Proceeds

Post 5184

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Interpleader Protects All Claimants Against Life Policy and the Insurer

In Metropolitan Life Insurance Company v. Selena Sanchez, et al, No. 2:24-cv-03278-TLN-CSK, United States District Court, E.D. California (September 3, 2025) the USDC applied interpleader law.
Case Overview

This case involves an interpleader action brought by the Metropolitan Life Insurance Company (Plaintiff-in-Interpleader) against Selena Sanchez and other defendants (Defendants-in-Interpleader).

Key Points

Plaintiff-in-Interpleader’s Application:

The Plaintiff-in-Interpleader filed an amended application for leave to deposit funds into the Court registry. This application was granted by the Court.

Funds Deposit:

The Plaintiff-in-Interpleader is required to deposit a check payable to the Clerk of the United States District Court for the Eastern District of California in the amount of $10,159.99 plus any applicable interest into an interest-bearing account in the Court Registry.

Purpose of Interpleader:

The interpleader action aims to resolve the issue of multiple claims to the remaining life insurance benefits of the Decedent, Neal Sanchez. The Plaintiff-in-Interpleader seeks to deposit the funds to relieve itself from responsibility while the Court determines the rightful beneficiaries.

Beneficiary Designations:

There is an unresolved issue regarding whether the Decedent intended to change his beneficiary designations for his life insurance benefits due to technical malfunctions in the benefits system. This has led to uncertainty about the distribution of the remaining Plan benefits.

Legal Analysis

The Plaintiff-in-Interpleader seeks to deposit the funds to relieve itself from responsibility while the Court determines the rightful beneficiaries. The interpleader action is brought pursuant to Federal Rule of Civil Procedure 22 and 28 U.S.C. § 1335, which permit a party to file an interpleader claim when the party faces possible exposure to multiple liabilities from the defendants. The core purpose of Rule 67 is to relieve a party who holds a contested fund from responsibility for disbursement of that fund among those claiming some entitlement thereto. The decision to allow the deposit of property pursuant to Rule 67 is discretionary.

Beneficiary Designations

There is a significant issue regarding the Decedent’s beneficiary designations. The Decedent’s beneficiary designation form for the Plan dated March 5, 2014, designates four Defendants-in-Interpleader as equal beneficiaries of 25% each. However, due to a technical error in the benefits system, it is unknown if the Decedent intended to make the same beneficiary designation changes to his life insurance as his 401(k). This has led to the Plaintiff-in-Interpleader being unable to determine the rightful beneficiaries without risking exposure to multiple claims and liabilities.

Court’s Findings

The Court found that the deposit of the remaining life insurance benefits into an interest-bearing account is appropriate and granted the Plaintiff-in-Interpleader’s amended application. This decision was based on the unresolved issue regarding whether the Decedent intended to change his beneficiary designations for his life insurance benefits due to technical malfunctions in the benefits system. This has led to uncertainty about the distribution of the remaining Plan benefits. This action protects the Plaintiff-in-Interpleader from potential liability and ensures that the funds are distributed according to the Court’s determination.

ZALMA OPINION

When multiple parties claim the benefits of a life insurance policy and litigate against the insurer federal rules allow the insurer to deposit the proceeds of the life insurance policy into an interest bearing account under the control of the court and protects the interests of all the claimants and the insurer and gives the court time to determine which beneficiary and how much each are entitled to receive.

(c) 2025 Barry Zalma & ClaimSchool, Inc.

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00:06:34
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See the full video at and at and at https://zalma.com/blog and more than 5150 posts.

You Plead Guilty You Must Accept the Sentence

In Commonwealth Of Pennsylvania v. Mark D. Redfield, No. 20 WDA 2025, No. J-S24010-25, Superior Court of Pennsylvania (September 19, 2025) the appellate court reviewed the case of Mark D. Redfield, who pleaded guilty to third-degree murder for killing April Dunkle with malice using a rifle.

Affirmation of Sentence:

The sentencing court’s judgment was affirmed, and jurisdiction was relinquished, concluding no abuse of discretion occurred.

Reasonable Inference on Trigger Pulling:

The sentencing court reasonably inferred from the guilty plea facts that the appellant pulled the trigger causing the victim’s death, an inference supported by the record and consistent with the plea.

Guilty Plea Facts:

The appellant admitted during the plea hearing...

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September 25, 2025
Prelitigation Communications Privileged

The Judicial Proceedings Privilege
Post 5196

Posted on September 25, 2025 by Barry Zalma

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Judicial Proceeding Privilege Limits Litigation

In David Camp, and Laura Beth Waller v. Professional Employee Services, d/b/a Insurance Branch, and Brendan Cassity, CIVIL No. 24-3568 (RJL), United States District Court, District of Columbia (September 22, 2025) a defamation lawsuit filed by David Camp and Laura Beth Waller against Insurance Branch and Brendon Cassity alleging libel based on statements made in a letter accusing them of mishandling funds and demanding refunds and investigations.

The court examined whether the judicial proceedings privilege applieD to bar the defamation claims.

Case background:

Plaintiffs Camp and Waller, executives of NOSSCR and its Foundation, sued defendants Insurance Branch and Cassity over a letter alleging financial misconduct and demanding refunds and audits. The letter ...

00:07:56
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September 24, 2025
Untrue Application for Insurance Voids Policy

Misrepresentation or Concealment of a Material Fact Supports Rescission

Post 5195

Don’t Lie to Your Insurance Company

See the full video at and at https://rumble.com/v6zefq8-untrue-application-for-insurance-voids-policy.html and at https://zalma.com/blog plus more than 5150 posts.

In Imani Page v. Progressive Marathon Insurance Company, No. 370765, Court of Appeals of Michigan (September 22, 2025) because defendant successfully established fraud in the procurement, and requested rescission, the Court of Appeals concluded that the Defendant was entitled to rescind the policy and declare it void ab initio.

FACTS

Plaintiff's Application:

Plaintiff applied for an insurance policy with the defendant, indicating that the primary use of her SUV would be for "Pleasure/Personal" purposes.

Misrepresentation:

Plaintiff misrepresented that she would not use the SUV for food delivery, but records show she was compensated for delivering food.

Accident:

Plaintiff's SUV was involved in an accident on August ...

00:07:48
September 09, 2025
The Dishonest Chiropractor/Physician

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Post 5185
Posted on September 8, 2025 by Barry Zalma

See the full video at https://lnkd.in/gePN7rjm and at https://lnkd.in/gzPwr-9q

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How Elderly Doctors Fund their ...

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September 08, 2025
The Dishonest Chiropractor/Physician

How a Need for Profit Led Health Care Providers to Crime
Post 5185
Posted on September 8, 2025 by Barry Zalma

See the full video at https://lnkd.in/gePN7rjm and at https://lnkd.in/gzPwr-9q

This is a Fictionalized True Crime Story of Insurance Fraud from an Expert who explains why Insurance Fraud is a “Heads I Win, Tails You Lose” situation for Insurers.

The Dishonest Chiropractor/Physician

How a Need for Profit Led Health Care Providers to Crime

See the full video at and at

This is a Fictionalized True Crime Story of Insurance Fraud from an Expert who explains why Insurance Fraud is a “Heads I Win, Tails You Lose” situation for Insurers. The story is designed to help to Understand How Insurance Fraud in America is Costing Everyone who Buys Insurance Thousands of Dollars Every year and Why Insurance Fraud is Safer and More Profitable for the ­­­Perpetrators than any Other Crime.

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September 03, 2025

Barry Zalma: Insurance Claims Expert Witness
Posted on September 3, 2025 by Barry Zalma
The Need for a Claims Handling Expert to Defend or Prove a Tort of Bad Faith Suit

© 2025 Barry Zalma, Esq., CFE

When I finished my three year enlistment in the US Army as a Special Agent of US Army Intelligence in 1967, I sought employment where I could use the investigative skills I learned in the Army. After some searching I was hired as a claims trainee by the Fireman’s Fund American Insurance Company. For five years, while attending law school at night while working full time as an insurance adjuster I became familiar with every aspect of the commercial insurance industry.

On January 2, 1972 I was admitted to the California Bar. I practiced law, specializing in insurance claims, insurance coverage and defense of claims against people insured and defense of insurance companies sued for breach of contract and breach of the implied covenant of good faith and fair dealing. After 45 years as an active lawyer, I asked that my license to practice law be declared inactive ...

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